SUPREME COURT OF THE STATE OF NEW YORK
CITY OF NEW YORK
COUNTY OF NEW YORK
CRIMINAL TERM: SPECIAL NARCOTICS PARTS
THE PEOPLE OF THE STATE OF NEW YORK
-AgainstRogelio Lucas and Lydia Lucas,

Defendants.

THE GRAND JURY OF THE SPECIAL NARCOTICS COURTS OF THE CITY
OF NEW YORK, by this indictment, accuses the defendants Rogelio
Lucas and Lydia Lucas of the crime of CONSPIRACY IN THE FOURTH
DEGREE, P.L. §105.10(1), committed as follows:
The defendants, in the County of New York, City of New
York, from on or about January 2, 2009, to on or about June 4,
2015, with intent that conduct constituting CRIMINAL SALE OF A
PRESCRIPTION FOR A CONTROLLED SUBSTANCE OR OF A CONTROLLED
SUBSTANCE BY A PRACTITIONER OR PHARMACIST, a Class C felony, be
performed, did knowingly and intentionally agree with each other
to engage in and cause the performance of such conduct as would
constitute the above-mentioned Class C felony.
PREAMBLE
It was part of the conspiracy for Rogelio Lucas, a medical
practitioner, to write prescriptions for oxycodone other than in
good faith in the course of his professional practice.
It was part of the conspiracy for Lydia Lucas to manage the
daily operation and finances of the medical practice of Rogelio
Lucas.

 OVERT ACTS
In furtherance of said conspiracy, and to achieve the
objects thereof, the following overt acts, among others, were
committed:
1.

On or about July 26, 2011, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
2.

On or about August 12, 2011, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
3.

On or about September 1, 2011, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
4.

On or about September 15, 2011, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
5.

On or about October 17, 2011, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
6.

On or about November 18, 2011, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
7.

On or about December 19, 2011, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
8.

On or about December 22, 2011, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
9.

On or about January 16, 2012, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
10.

On or about January 24, 2012, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
11.

On or about February 22, 2012, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.

 12.

On or about February 24, 2012, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
13.

On or about March 16, 2012, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
14.

On or about March 22, 2012, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
15.

On or about April 19, 2012, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
16.

On or about April 26, 2012, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
17.

On or about May 16, 2012, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
18.

On or about May 17, 2012, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
19.

On or about June 16, 2012, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
20.

On or about July 5, 2012, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
21.

On or about July 31, 2012, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
22.

On or about September 14, 2012, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
23.

On or about October 17, 2012, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
24.

On or about November 14, 2012, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.

 25.

On or about December 21, 2012, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
26.

On or about January 16, 2013, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
27.

On or about February 15, 2013, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
28.

On or about April 10, 2013, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
29.

On or about May 10, 2013, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
30.

On or about June 7, 2013, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
31.

On or about July 10, 2013, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
32.

On or about December 31, 2013, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
33.

On or about November 12, 2014, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
34.

On or about February 6, 2015, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
35.

On or about March 11, 2015, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
36.

On or about April 13, 2015, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.
37.

On or about May 13, 2015, Rogelio Lucas wrote a

prescription for oxycodone for a person known to the Grand Jury.

 SECOND COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about July 26, 2011, being a practitioner as that
term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

THIRD COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about August 12, 2011, being a practitioner as that
term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than

 in good faith in the course of his professional practice.

FOURTH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about September 1, 2011, being a practitioner as
that term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

FIFTH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about September 15, 2011, being a practitioner as
that term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an

 individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

SIXTH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about October 17, 2011, being a practitioner as that
term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

SEVENTH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about November 18, 2011, being a practitioner as

 that term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

EIGHTH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about December 19, 2011, being a practitioner as
that term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

NINTH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:

 Said defendants, in the County of New York, City of New
York, on or about December 22, 2011, being a practitioner as
that term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

TENTH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about January 16, 2012, being a practitioner as that
term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

ELEVENTH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED

 SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about January 24, 2012, being a practitioner as that
term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

TWELFTH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about February 22, 2012, being a practitioner as
that term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

THIRTEENTH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further

 accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about February 24, 2012, being a practitioner as
that term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

FOURTEENTH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about March 16, 2012, being a practitioner as that
term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

 FIFTEENTH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about March 22, 2012, being a practitioner as that
term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

SIXTEENTH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about April 19, 2012, being a practitioner as that
term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than

 in good faith in the course of his professional practice.

SEVENTEENTH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about April 26, 2012, being a practitioner as that
term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

EIGHTEENTH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about May 16, 2012, being a practitioner as that
term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an

 individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

NINETEENTH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about May 17, 2012, being a practitioner as that
term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

TWENTIETH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about June 16, 2012, being a practitioner as that

 term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

TWENTY FIRST COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about July 5, 2012, being a practitioner as that
term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

TWENTY SECOND COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:

 Said defendants, in the County of New York, City of New
York, on or about July 31, 2012, being a practitioner as that
term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

TWENTY THIRD COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about September 14, 2012, being a practitioner as
that term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

TWENTY FOURTH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED

 SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about October 17, 2012, being a practitioner as that
term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

TWENTY FIFTH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about November 14, 2012, being a practitioner as
that term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

 TWENTY SIXTH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about December 21, 2012, being a practitioner as
that term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

TWENTY SEVENTH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about January 16, 2013, being a practitioner as that
term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than

 in good faith in the course of his professional practice.

TWENTY EIGHTH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about February 15, 2013, being a practitioner as
that term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

TWENTY NINTH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about April 10, 2013, being a practitioner as that
term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an

 individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

THIRTIETH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about May 10, 2013, being a practitioner as that
term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

THIRTY FIRST COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about June 7, 2013, being a practitioner as that

 term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

THIRTY SECOND COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about July 10, 2013, being a practitioner as that
term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

THIRTY THIRD COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:

 Said defendants, in the County of New York, City of New
York, on or about December 31, 2013, being a practitioner as
that term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

THIRTY FOURTH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about November 12, 2014, being a practitioner as
that term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

THIRTY FIFTH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED

 SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about February 6, 2015, being a practitioner as that
term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

THIRTY SIXTH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about March 11, 2015, being a practitioner as that
term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

THIRTY SEVENTH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further

 accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:
Said defendants, in the County of New York, City of New
York, on or about April 13, 2015, being a practitioner as that
term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

THIRTY EIGHTH COUNT
AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendants Rogelio Lucas and Lydia Lucas of the
crime of CRIMINAL SALE OF A PRESCRIPTION FOR A CONTROLLED
SUBSTANCE OR OF A CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST, P.L. §220.65(1), committed as follows:

 Said defendants, in the County of New York, City of New
York, on or about May 13, 2015, being a practitioner as that
term is defined in section thirty-three hundred two of the
Public Health Law, knowingly and unlawfully sold to an
individual known to the grand jury a prescription for a
controlled substance, to wit, oxycodone, while acting other than
in good faith in the course of his professional practice.

BRIDGET G. BRENNAN
Special Assistant District Attorney

 Counsel

Filed day of

PM-2 #6
NA Indictment
Part 61

,2015

THE PEOPLE OF THE STATE OF NEW YORK

Pleads
-againstRogelio Lucas and Lydia Lucas,
Bail

Defendants.
INDICTMENT
CONSPIRACY IN THE FOURTH DEGREE
(1 COUNT)
CRIMINAL SALE OF A PRESCRIPTION FOR A
CONTROLLED SUBSTANCE BY A PRACTITIONER OR
PHARMACIST
(37 COUNTS)

ADA RYAN SAKACS/PART PDIU
P.L. §105.10(1), P.L. §220.65(1)
BRIDGET G. BRENNAN
Special Assistant District Attorney

A TRUE BILL

Foreperson